United States
Environmental Protection
Agency
Office of Water
4301
EPA-820-R-95-007
July 1995
Industrial Pollution
Prevention Project (IPS)
Summary Report
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NOTE TO READER: The format of this summary report has been designed so that the
findings and conclusions of each IPS document or overall document
subject are contained in an exact even number of pages. This makes
it possible to copy pages and obtain a handy, precisely self-contained
summary of a particular document or overall document subject.
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SUMMARY REPORT
of the
INDUSTRIAL POLLUTION PREVENTION PROJECT (IP3)
As part of EPA's emphasis on pollution prevention, the Agency set aside 2% of its FY1991 and
FY1992 contract budgets for new pollution prevention initiatives. One of the proposed
initiatives selected for funding and initiated in 1991 was the Industrial Pollution Prevention
Project (IPS). The IPS was an Agency-wide, multi-media project undertaken to examine:
O how industrial pollution prevention can be incorporated into EPA's regulatory
framework, and
O how the pollution prevention ethic can be promoted throughout industry, the
public, and all levels of government.
Outputs
In addition to establishing the institutional framework for ongoing pollution prevention (P2)
implementation in four geographical regions, the IPS has produced the following 23 documents:
P2 Barriers and Incentives Study
Statute Analysis
Analysis of EPA's Effluent Guidelines Process
An Effluent Guidelines Retrospective on the Leather Tanning Industry
Studies of P2 Technologies for Selected Effluent Guidelines Industries
IPS Focus Group Recommendations: The Effluent Guidelines Process
Waivers for Technology Innovation
Proposed Clean Water Act Legislation
International P2 Case Studies
New England Demonstration Project
New England Demonstration Project: EPA Region 1 Report
New England Demonstration Project: Building Partnerships for P2
Nebraska Demonstration Project
Nebraska Demonstration Project: Technical Report #1
Nebraska Demonstration Project: Technical Report #2
Southern California Demonstration Project
Southern California Demonstration Project: Technical Report
Pacific Northwest Demonstration Project
Pacific Northwest Demonstration Project: Simpson Tacoma P2 Plan
Pacific Northwest Demonstration Project: Model P2 Plan (Pulp and Paper Mill)
Pacific Northwest Demonstration Project: Bibliography
Consumer Education Handbook
IPS Focus Group Recommendations: P2 Information Sharing
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Participants
The IP3 was funded by six EPA Offices:
Office of Water
Office of Air and Radiation
Office of Solid Waste
Office of Prevention, Pesticides, and Toxic Substances
Office of Policy, Planning, and Evaluation
Office of the Administrator
Some funds also were provided by the University of Nebraska (i.e., matching funds
associated with an IPS grant to the university).
EPA's Office of Water, which initially proposed the project, was designated the lead office. The
Office of Water's Jim Lund, who developed the project, was designated the Director of the IPS.
Project participants included all of those mentioned above, plus:
Office of General Counsel
Office of Enforcement
Office of Research and Development
EPA Region 1
EPA Region 7
EPA Region 9
EPA Region 10
Commonwealth of Massachusetts
State of New Hampshire
State of California
State of Washington
Local Government Commission in California
Merrimack (River) Business Environmental Network
Northeast Business Environmental Network
POTWs in Massachusetts and in New Hampshire
POTWs in California
Several industrial laundries in California
Simpson Tacoma Kraft Company in Tacoma, Washington
Behlen Manufacturing Company in Columbus, Nebraska
In addition, a 23-member IPS Focus Group of stakeholders - comprised of representatives from
industry, labor, environmental groups, academia, and all levels of government (federal, state, and
local) ~ was established through the National Advisory Council for Environmental Policy and
Technology (NACEPT) and participated in all aspects of the project.
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A SUMMARY OF MAJOR IP3 FINDINGS AND CONCLUSIONS
(from each of the 23 IPS documents)
1. P2 Barriers and Incentives Study
(Industrial Pollution Prevention: Incentives and Disincentives (EPA-820-R-94-004))
This study examines the most promising incentives to overcome existing barriers to industrial
pollution prevention.
It examines the regulatory, economic, technical/informational, and management/institutional
factors that affect whether an industrial facility decides to adopt or fails to adopt P2 measures and
suggests to policy makers appropriate incentives to overcome each of the barriers.
It also relates its findings and conclusions specifically to the metal finishing industry.
Value
Industries can learn from the information in the numerous case studies presented.
Government policy makers and regulators can learn from the case studies and from the
study's detailed discussions of its findings.
Major Findings and Conclusions
The study concluded that the four most important general motivators for P2 are:
O Economics — cost savings
O Technical and financial assistance — especially for small companies.
O Open communication — between the regulator and the regulated.
And most important of all,
O Flexibility — especially regulatory. Can work best if multi-media.
The study found, however, that the key "trigger" motivator for P2 is:
O A stringent regulation or an enforcement action.
The study presents an overview of the P2 incentives and disincentives and suggests
appropriate incentives to overcome each of the disincentives: [see the matrices below]
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Through numerous telephone interviews and site visits, the study also developed some
findings and conclusions related specifically to the metal finishing industry:
O Mass-based standards are motivators for P2. Regulators should be
allowed the flexibility to use mass-based standards to achieve effluent
goals.
O When enforcement and compliance activities are tied to a strong P2
message, they can be a key motivator for facilities to adopt P2.
O Existing categorical standards do not provide an incentive for P2
because they are outdated and are being increasingly superseded by non-
technology based standards.
O Zero-discharge systems hold much promise for metal finishers seeking to
maximize water efficiency and chemical recycling/reuse. But there are
both regulatory and technical/informational barriers.
O Economic factors have the potential to be an important incentive for P2.
But there are often significant barriers — a fear of noncompliance, a lack of
financial assistance, a general "status quo" inertia (e.g., wary of changes,
preferring the security of proven profits under existing conditions) —
countering this potential. Also, for small metal finishers, total cost
accounting is usually not an effective tool for promoting P2.
O Flexibility in the regulatory network, supportive assistance/outreach, and
collaborative relationships between industry, regulators, and the public
can foster continuous, industry-wide improvement in P2.
The study concludes by presenting:
O a detailed case example of the San Francisco Regional Water Quality
Control Board in California, which illustrates the successful integration
of P2 incentives to overcome barriers.
The Appendices to the study include:
O 14 case studies (nine from the site visits made during the study and five
more taken from the Pollution Prevention Information Clearinghouse),
which describe different companies, their situations, what specific P2
measures they chose to undertake (or chose not to undertake), what
influenced the decisions they made, and the results.
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Regulatory Factors in Pollution Prevention Decisions
REGULATORY IMCENTIVES
PHffl If A
flexible, multi-media
regulatory framework
single-media regulatory
framework
specific toxics use
reduction laws or facility
planning statutes that
encourage firms to do P2
opportunity assessments and
audits
single-media permits that
focus on end-of-pipe
Tffn-i -i romcn-t-a
compliance inspections
where NOVs are tied to a
pollution prevention
message (e.g., referral to
state technical assistance
program)
single-media inspections
with no pollution
prevention message (i.e.,
quick-fix, end-of-pipe
compliance focus)
flexibility within
compliance and enforcement
programs (e.g.,extended
compliance schedules phased
to pollution prevention
activities, "soft landings"
for technical failure of
innovative technologies)
inflexible approach to
media-specific enforcement
actions that allows no time
for process innovation or
exploration of pollution
prevention solutions
strict local limits, with
POTW ordinance authority to
implement/enforce
reliance on EPA categorical
limits which may be
outdated and set too low a
compliance level
regulatory pressures on
POIffis such as EPA sludge
regulations, or air toxics
reduction requirements,
motivating POTWs to push
upstream sources to lower
metals in wastewaters—
ideally through pollution
prevention measures
specific regulatory
"barriers* such as RCRA
Part B permit requirements
for facilities implementing
reuse/recovery technologies
or "zero discharge" systems
SEPs with pollution
prevention requirements;
promotion of pollution
prevention alternatives in
enforcement case context
guida
used by
permit writers that may be
outdated and focus on end-
of-pipe solutions
mass-based or total
loadings—based standards—
especially for water
intensive industries—that
may. encourage water
reclamation/recycling/re—
use
concentration-based
standards that may
water
reclamation/recycling/
use
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Economic Factors in Pollution Prevention Decisions
HOOMGMIC
ECONOMIC DISINCENTIVES
lower facility operational
costs that nay include:
— environmental management
cost savings (e.g., from
eliminating RCRA sludges,
or decreased wastewater
treatment costs)
— production or process
cost savings due to lower
material or chemical use
— utility cost savings due
to lower water, sewer, and
energy usage
— lower liability costs
capital investment
requirement difficult or
impossible for many firms-
— firms may have limited
Or no Capital avajlabilifcy
due to low profit margins,
competing investment
priorities, or too much
environmental liability (a
"bad risk" for lenders)
— "sunken investments'' in
conventional pollution
control equipment
— many small firms--
especially "job shops"—
cannot tolerate down-time
for equipment upgrades or
process change/experiments
fee structures based on
pollutant loadings (permit
fees, POTW fees, etc.) can
act as economic incentive
for pollution prevention
economies of scale for some
technologies may not be
realistic at smaller firms
(e.g., metal recovery
technologies, automatic
systems vs. batch)
R & D challenge grants, low
interest loans, tax breaks
for equipment upgrades, and
other funding assistance
mechanisms can be powerful
incentive—but only if
message gets to company
about availability and if
application process is not
onerous
R & D costs for new
technologies and/or process
mm^-if ir!a<"jr>na may be
difficult to bear — also,
firm must be concerned with
enforcement
related costs if technology
fails
enhanced product quality
and/or corporate image may
lead to higher revenues
customer dissatisfaction
with changed product may
mean loss of revenue
full/total cost accounting
methodologies can help
firms identify economic
savings and opporr-'mi *•-•?*»
not readily apparent—but
there is a real need for
simpler, user-friendly,
methods such as a; quick
checklist or worksheet that
fimm can USB
full/total cost accounting
to justify pollution
prevention expenditures can
be ttttplexr time-consuming,
and expensive (especially
for small firms)
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Technical/Informational Factors in Pollution Prevention
Decisions
TBCH/IKFO INCENTIVES
TBCH/INPO
technical assistance to
facility via state TAP or
POTW pretreatment programs
can overcome many
informational barriers
facility unfamiliar with
pollution prevention and
potential for in-process
changes
targeted outreach to a
particular industry sector
via pollution prevention
workshops, seminars, or
training—provide forum for
industry to share success
stories and concerns
facility uncertain of
pollution prevention's
ability to meet discharge
limits; afraid to be first
or to take risk
vendor lists or
certification programs to.
assure prospective
purchasers/service users
that vendor is both
reputable and knowledgeable
about pollution prevention
technologies
unscrupulous vendors who
misinform, misrepresent
and/or install inferior
equipment; so-called
"pollution prevention
experts" who sell a product
then disappear when the
system falls and the
facility falls out of
compliance
detailed knowledge of waste
generation and chemical
usage via facility audit/
opportunity assessment
lack of detailed knowledge
of waste streams and extent
of in-process use of toxic
chemicals
trade and industry
associations that encourage
and ^ "* ag**ni TVM"** pollution
prevention information
customer satisfaction
concerns—potential impacts
of pollution prevention on
product quality,
appearance,, or performance
that could translate into
loss of customer acceptance
permit writer and inspector
training on how pollution
prevention can achieve,
maintain, or even go beyond
compliance
chemical or product
substitution concerns: will
it: a) do the job; b) be
consistently available; c)
not become expensive; and
d) not trigger some other
unforeseen regulatory
nightmare
proprietary information
concerns—disincentive to
sharing information, data,
and/or experiences with new
processes
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Management/Institutional Factors in Pollution
Prevention Decisions
noamvES
DISIMCEMTIVES
corporate policy supporting
pollution prevention or
incorporating it into
strategic planning
accountability within
management structure for
integrated (i.e., across
no upper management
ccmnitment to pollution
prevention
Oigppj'f^fnpnfcg _ OfOUDS • OH?
divisions) environmental
responsibility
lack of coordination and
accountability among
different groups in the
company (e.g., process
engineers/product design
engineers not talking to
environmental engineers)
willingness tc take risks
low tolerance for failure;
policy of risk avoidance
willingness to engage in
open dialogue with both
regulators and t^
assistance personnel
closed shop mentality;
afraid to ask questions—
"What I don't know won't
hurt me."
TQM programs that empower
employees to seek pollution
prevention opportunities
bean-counting disincentives
at regulatory agencies that
tie performance reviews to
number of enforcement
cases, number of permits,
etc. instead of rewarding
quality orwi mninorrt-al
results
potential for favorable
publicity; pollution
prevention helps present a
"good guy" image; like to
show progress (e.g., lower
TRI na«b«r«)
do not want to
attention to themselves—
e.g., if company has been
"burned" once by EPA, will
be reluctant to try
anything now which might
draw more attention
tiv« «nvir
within (and between)
regulatory agencies;
openess to pollution
inertia: "If it ain't
broke, don't fix it."
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2. Statute Analysis
( The Tools of Prevention (An Environmental Law Institute Report done for the IP3) )
This analysis identifies and examines the industrial pollution prevention opportunities in two
major environmental statutes: The Clean Water Act (CWA) and the Resource Conservation and
Recovery Act (RCRA).
It seeks to discover the extent to which there is authority — within the existing legislation ~ to
move beyond controlling pollution to preventing it in the first plate.
Value
Government policy makers and regulators can learn, from this thorough analysis, about
statutory authorities which currently exist in the provisions of the CWA and RCRA.
Major Findings and Conclusions
The analysis concludes:
O Existing statutes provide substantial (and still largely untapped)
authority to promote industrial pollution prevention using a variety of
regulatory methods.
O The existing statutes provide more than adequate authority to
promote industrial pollution prevention boldly, vigorously, and
without delay.
The CWA and RCRA each provide opportunities to use already familiar tools to promote
P2. The analysis presents four strategies already provided under current law: direct
regulatory action, standard setting, incentives, and information management/outreach.
With each strategy, the analysis identifies specific opportunities for pollution prevention
under the existing statutory authorities. Some examples of the opportunities identified by
the analysis are the following:
(NOTE: Statutory opportunities are not always easily translatable into implementation.)
1. Direct Regulatory Action
Banning the discharge of highly toxic pollutants. (CWA)
Section 307(a)(2), though seldom invoked, nonetheless remains a
viable option for banning the discharge of toxic pollutants.
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Putting conditions on NPDES permits that would directly
promote pollution prevention. (CWA)
Requiring, for example, pollution prevention BMPs or a facility
plan identifying P2 opportunities can be a condition of a permit.
This could be done on a permit-by-permit basis or generically.
Requiring waste reduction plans as a condition of receiving a
treatment, storage, and disposal permit. (RCRA)
A limitation is that this could apply only to generators required to
obtain permits for on-site treatment, storage, and disposal — a
subpopulation of all RCRA-regulated generators.
Enhancing the Waste Minimization Program by doing more
with generator certification and biennial reporting. (RCRA)
Despite a tentative legislative history, the language of the statute
provides the authority to require: (1) under generator certification,
a description of the waste reduction program in place and why a
more aggressive program is not economically practicable; and (2)
under biennial reporting, development of a waste reduction plan
and reports on results achieved.
Imposing specific P2 measures as part of agency enforcement
settlements with violators.
This can include not only P2 measures which correct the violation
but also ones to be implemented additionally.
2. Setting Standards
Developing effluent guidelines that move industries toward
preventing pollution. (CWA)
Although the effluent guidelines are neutral with respect to
whether an industry uses a particular technology or preventive
method, EPA has the authority to promote P2 by using preventive
methods as the basis for the guidelines.
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Using water quality standards to promote prevention. (CWA)
"the wasteload allocation process under Section 303 can be
employed to leverage the use of P2 measures in chosen sectors.
Also, under Section 304, toxicity reduction evaluations (TREs) can
be used to identify P2 opportunities for reducing discharges.
Using P2 technologies in setting BOAT standards. (RCRA)
Despite debate over the term "treatment" in Section 3004(m), the
statute provides authority to develop prevention-based BDAT
standards under the land disposal restrictions program.
3. Incentives
Charging a fee for pollution. (CWA)
Some states already have fee systems — but primarily to raise
revenue, not induce P2. Section 402 arguably provides the
authority to institute an incentive-based fee system. But absence of
clear congressional authorization might be a problem.
Allowing pollution trading. (CWA)
Unlike incentive-based discharge fees, pollution trading has
already been implemented by environmental regulators in the
United States. For several reasons, trading under the CWA may be
appropriate only for conventional water pollutants.
Extending compliance deadlines for innovative processes or
technologies. (CWA)
Section 301(k), intended to encourage innovation through
compliance extensions, failed (see page 17 below). A revised
provision (see page 19 below) can be effective and promote P2.
Extending compliance deadlines for newly-listed wastes.
(RCRA)
Statutory authority exists to give generators of newly-listed wastes
a lengthened period of time to implement source reduction
measures before the effective date of required waste management
obligations. Enforcement penalties could possibly be assessed
against generators who use the extension improperly.
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Creating a P2 EPA procurement policy.
A precedent for using procurement incentives already exists under
RCRA, although it is designed to promote recycling rather than
prevention. EPA could promote P2 more directly by revising its
own current procurement policy and establishing a P2 procurement
policy as an "additional" socioeconomic program under Part 26 of
the FAR. Such a procurement policy could promote P2 by the
choice of products purchased. The FAR anticipates that agencies
will use their procurement policies to advance socioeconomic
programs of this nature.
4. Information Management and Outreach
Measuring progress in pollution prevention. (RCRA)
There are several ways (detailed in the analysis) that RCRA's
biennial reporting system can be used to measure P2 progress,
(including integration with the Toxics Release Inventory (TRI)).
Publicizing P2 performance. (CWA)
EPA has authority to identify firms that have risen above their
peers in implementing P2, and it can throw the spotlight on those
who continue to lag behind. A P2 awards program could be
established, for example, under Section 501(e)(l) of the CWA.
Providing P2 technical assistance. (CWA+RCRA)
EPA can use its information-gathering authorities to gather P2
information and then share it (except that which is proprietary).
Establishing P2 as a top priority for grant-making.
(CWA+RCRA)
Section 104(a) of the CWA specifically authorizes P2 research.
Similarly, so does RCRA under subchapter VII. Under its general
authority, EPA can establish research priorities.
The analysis ends with these two sentences:
"...There is a [statutory] basis to begin building a pollution prevention program
based on solid regulatory action. The tools are clearly there."
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3. Analysis of EPA's Effluent Guidelines Process
( Consideration of P2 in EPA's Effluent Guideline Development Process (EPA-820-R-95-008))
This analysis describes in detail the steps of the effluent guideline development process and
identifies where in the process pollution prevention can be considered.
Value
Government policy makers and regulators can learn and understand how the effluent
guideline development process can and does incorporate P2 considerations.
Major Findings and Conclusions
The flowchart (next page) lays out the 18 steps of the effluent guideline development
process and identifies those steps (the shaded boxes in the flowchart) where pollution
prevention considerations and decisions can most appropriately be made.
Also, a "snapshot" of effluent guideline P2 considerations, taken in 1995, is included in
the analysis to show how EPA's effluent guidelines program is now promoting P2 in
the specific effluent guidelines (Metal Products and Machinery, Pesticide Formulating
and Packaging, Pharmaceuticals, and Pulp and Paper) currently under development.
The analysis ends with a listing of challenges and issues that remain to be resolved
before P2 can be fully realized within the effluent guidelines process, such as:
enabling the Effluent Guidelines Program to become more multi-media oriented
e.g., To what degree should EPA set effluent standards which result in
the most beneficial overall impact on the environment, accounting
for all media? Should budgets for rule development be
administered by cross-media teams rather than by single-media
program offices? Should resources for rule development be
allocated specifically for multi-media analysis as a condition for
program funding? Should EPA have the authority in an effluent
guideline to prohibit use of technologies that have a significant
adverse effect on the environment through other media?
finding a way to foster the flexibility that encourages P2 that can surpass BAT
e.g., see pages 15 through 22 below.
achieving a P2 mindset in everyone, not only in standard-setting, but throughout
the effluent guidelines process — including permitting, compliance, and
enforcement.
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Effluent Guidelines Flowchart
REGULATION DEVELOPMENT PROCESS
Critical path
Non-Critical path
Industry Designated in
Effluent Guidelines Plan
Review available data
- identify data gaps
id
SEPA
Effluent Guidelines Program
OVWOST/EAD 11/92
Proposed
Regulation
DeveJopnwnt Doeunwnl
Economic Impact Analysis
Environmental Assessment
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4. An Effluent Guidelines Retrospective on the Leather Tanning Industry
(Effluent Guidelines. Leather Tanning, and Pollution Prevention (EPA-820-R-95-006))
This study was undertaken to learn:
O in what ways and for what reasons a specific industry in the past already was
implementing P2 in order to comply with existing effluent guidelines; and
O to what degree the effluent guidelines development document for that industry
had already previously projected that outcome.
Value
Government policy makers and regulators can learn from the past.
Major Findings and Conclusions
(NOTE: This study was intended to serve as a case study within the leather tanning
industry and may not necessarily represent the leather tanning industry as a whole.)
The study found that:
O The industry was already implementing pollution prevention in the
past to meet the effluent guideline requirements.
Process changes and material substitutions were as
important in meeting the effluent guideline requirements as
end-of-pipe treatment.
O The effluent guideline requirements were the driving force behind the
implementation of pollution prevention — even if not the only reason.
Adopted primarily to meet the guideline requirements, P2
also brought improved product quality, process efficiency,
and reduced water supply and treatment/disposal costs.
O The effluent guideline development document projections, while quite
accurate generally in the areas of end-of-pipe technologies, did not
forecast all the aspects of the pollution prevention creativity that was
exercised by the industry.
Two major pollution prevention measures that were
implemented by the industry were not referenced in the
development document.
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5. Studies of P2 Technologies for Selected Effluent Guidelines Industries
( These were studies that were funded by the IPS and were an integral part of the current effluent
guidelines' development.)
Some technical studies examined specific P2 technologies for effluent guidelines currently under
development.
Government regulators and industry are able to learn about the technical characteristics
and effectiveness of specific P2 technologies.
Major Findings and Conclusions
Major results of these particular studies included the following:
O For pesticide formulating/packaging facilities' operations, membrane filtration
technology was examined through extensive on-site testing, as well as pilot
bench-scale testing. It performed well; it provided a high recovery rate for certain
active ingredients in the waste stream, thereby eliminating discharge of the
pollutants and allowing for recirculation of process water. However, it proved not
to be as flexible a technology as other alternatives. Also, in some applications the
membrane has a tendency to become fouled, needing replacement - making it a
relatively costly technology. Therefore, it was decided not to cost it out as a basis
for BAT in the proposed Pesticides Formulating, Packaging, and Repackaging
Effluent Guideline.
O For electroplating and metal processing industries, a new process for recovering
individual metals from plating baths and rinses was examined at a couple of
facilities. This particular process uses oxalic acid as a precipitant. The process
was found to work well. However, it was found that, while some facilities can use
it, others cannot. Therefore, lacking industry-wide application, it was not used as
a basis for effluent limitations in the proposed Metals Products and Machinery
Effluent Guideline. However, recovery methods are discussed in the guideline's
Development Document.
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6. IP3 Focus Group Recommendations: The Effluent Guidelines Process
( How Best to Promote P2 Through the Effluent Guidelines Process (EPA-820-R-94-002))
The 23-member IPS Focus Group was a stakeholders group — comprised of representatives from
industry, labor, environmental groups, academia, and all levels of government (federal, state, and
local).
The Group, for 18 months, provided — for the IPS — a forum for constructive dialogue among all
groups affected by adoption of industrial pollution prevention. The Group developed specific
recommendations to EPA on "How Best to Promote Industrial Pollution Prevention Through the
Effluent Guidelines Process."
Value
Government policy makers, regulators, and the Congress can learn what the stakeholders
themselves recommend, regarding P2 and the effluent guidelines process.
Major Findings and Conclusions
(NOTE: The Group considered the "effluent guidelines process" to include not only
effluent guideline development (i.e., standard-setting) but also permitting, compliance,
and enforcement.)
To promote more industrial pollution prevention, the effluent guidelines process
must (1) be more flexible, (2) address all media, and (3) impart a pollution
prevention mindset to everyone throughout the effluent guidelines process.
To accomplish this, EPA should adopt a specific new approach to the development
and achievement of Best Available Technology (BAT) limits.
1, EPA should provide industry with an alternative approach that is more
flexible than the strict requirement to attain a single Best Available
Technology (BAT) effluent limit.
Industry should be permitted to achieve a level of effluent reduction
different from the single BAT limit — provided the facility will
implement pollution prevention measures that will substantially
reduce total emissions (all media considered) below an EPA-
established emissions reduction threshold.
The alternative approach must ~ in EPA's (and the State's or POTW's)
opinion -- be clearly a better environmental choice than simply meeting
the single BAT limit. Otherwise, the alternative approach must not be
granted.
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To encourage an industrial facility to choose the alternative approach and
implement multi-media pollution prevention measures reducing total
emissions (all media considered), EPA should offer ~ along with the
alternative approach -- incentives on a case-by-case basis depending on the
situation. However, no incentive should be offered that would increase
harm to human health or the environment.
2. EPA should offer incentives to industry to implement pollution
prevention measures that reduce pollution beyond the traditional
single BAT limit. (The Group's report suggests some possible incentives,
including technical assistance (for implementing P2), extended permit
length, extended compliance schedules, "soft landings," forgiveness of
"brief excursions, awards, etc.)
3. To further the incorporation of P2 into the existing effluent guidelines
development process, EPA should:
Encourage P2 actively in all parts of all the Agency's programs.
Make the development of every effluent guideline multi-media.
Conduct more dialogue with industry during the process
modification/treatability studies and site reports.
Continue to explore P2 technology used overseas.
Use the P2 Information Clearinghouse (PPIC) in conjunction with
the effluent guideline Development Document.
ETC. (There are six more recommendations like these.)
In addition, to get industries to do more P2, EPA should:
Look for and find ways to develop and promulgate effluent
guidelines more quickly in order to cover more industries.
Make sure that enforcement personnel and policies promote P2.
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7. Waivers for Technology Innovation
(Providing Waivers From NPDES Permit Compliance Schedules For Industrial Pollution
Prevention Technology (EPA-820-R-94-003))
This study examines the innovative technology waiver provision of the Clean Water Act. (The
provision is Section 301(k) and Section 307(e) for direct and indirect dischargers, respectively.)
Section 301(k)/307(e) — hereinafter referred to simply as 301(k) ~ provided an opportunity for
permittees to request that the date for compliance be extended for up to three years (later changed
to two years) if they use innovative technology to meet or exceed permit limits.
P2 often is, or can be considered, innovative technology. So studying past experiences with
technology innovation provisions like 301(k) can be important to understanding the potential role
of such a provision and how to change it to enable it to be effective in promoting P2.
The study examines why the past 301(k) program did not work. It presents a detailed and
thorough legislative and regulatory history of the program.
It also includes a comparison to the variance program under the Clean Air Act and highlights
several successful programs at the national and state levels that have promoted innovative
technology.
The study concludes with some suggestions for a redesigned 301(k)-type program to promote
innovative technology and P2. (See the following section 8. on Proposed Clean Water Act
Legislation for a proposed revision of Section 301(k) for a reauthorized CWA.)
Government policy makers and the Congress can learn why 301(k) did not work and how
it can be changed to be successful. This understanding is especially important in the
context of the current CWA reauthorization process.
Major Findings and Conclusions
The study found:
O In the fourteen years from the creation of 301 (k) in 1977 until its
expiration in 1991, it was hardly ever used. On the basis of available EPA
records, there may have been as few as five 301(k) variance applications,
and only one variance approval (which had mixed results).
O Some of the reasons 301 (k) was not attractive and did not work were:
Regulatory uncertainty and conflict (e.g., 14 years of suits,
argument, and delay over regulations that never became final.)
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The 3-year (initially) extension offered was not enough time.
Uncertainty and high cost of the application process (e.g.,
EPA's lack of enthusiasm for the process and the unwanted (and
usually adverse) attention an exceptions process always brings.)
Lack of a "soft landing" (even for good-faith efforts)
O Overall, the risks of the process seemed to most companies to exceed the
benefits of the waiver.
O For EPA, the perceived problems were resources, the likelihood of
ingenuine applications, and the intensive nature of the exceptions process.
O Even though partial remedies for some of the past problems of a 3 01 (k)
process might include increased resources for permit writers, defined
progress steps for recipients of waivers, and some form of "soft landing"
mechanism, extension of the 301(k) process in its current form is
unlikely to be more successful in the future than it has been in the
past. Its fundamental flaw is that it requires relatively large resources to
make individual case decisions within an exceptions process that makes
each such decision highly visible, making all parties feel at risk.
O An alternative might be to establish criteria within the effluent guidelines
process for additional environmental goals which would need to be
included in any permit providing alternative compliance deadlines for
implementation of innovative technology. Such criteria could include
additional reductions in pollutant levels beyond the requirements in the
guideline, or defined additional multi-media reductions.
O While decisions on parameters for such tradeoffs might be difficult to
make, they would occur up front in a context of overall decisions affecting
all facilities covered by a guideline. The application process could then
become a more standardized process, with less risk and requiring fewer
resources. Furthermore, placing priority on environmental success rather
than individual technical judgments would remove many of the
troublesome issues that plagued 301(k).
O The result would be a standardized process combining greater regulatory
flexibility with pre-established parameters for compliance extension
tradeoffs. 'By placing priority on environmental success rather than
technological judgments, such an up-front approach to the parameters
could provide a more predictable and congenial atmosphere for the
implementation of technology innovation and prove to be a more workable
approach than the 301(k) program of the past.
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8. Proposed Clean Water Act Legislation
Aware of the IPS study on waivers for technology innovation (presented above in the preceding
section), Congressional staff requested technical assistance from EPA on revising Section
301(k)/307(e) in the CWA reauthorization process. This proposed legislation ~ rewriting
Sections 301(k) and 307(e) ~ was written by the IP3, approved by EPA, and provided in 1994 to
Congressional staff in both the House and the Senate upon their request.
It is based upon the Waivers for Technology Innovation study (presented immediately above),
the IP3 Focus Group Recommendations (see page 15 above), and work done by the Effluent
Guidelines Task Force which further developed the IP3 Focus Group Recommendations.
It can serve as an improved Section 301(k)/307(e), resulting in a more effective CWA and
increased implementation of innovative technology and P2. With the CWA undergoing
reauthorization, this proposed legislation has been especially timely.
The Rationale Underlying the Proposed Legislation
O Pollution prevention and technology innovation should be promoted in the
reauthorized Clean Water Act.
O A simple way to do this is through a technology innovation provision — but
not one like the old 301(k) provision. The old 301(k) provision did not work, and
another one like it will still not work (see discussion on preceding page).
O Three basic changes need to be made to the old 301(k) provision to make it
work and successfully promote pollution prevention and technology innovation.
1) Industry must be given sufficient time to enable the innovation to
succeed (e.g., up to three years from the date for compliance
(which would be up to six years from effluent standards
promulgation)).
2) If industry gets that much time, the provision must require
enhanced environmental results (i.e., either better results in
water or the same results in water with better results in other
media).
3) The tradeoff parameters need to be predefined up front (e.g., hi
some regulatory document) but still provide for regulatory
flexibility (e.g., options for industry, such as the option referred to
in the parentheses in 2) above).
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O The provision will work, only if it has the support of all the stakeholders. With
the above three basic changes, all of the stakeholders get what they need to
make the provision work.
1) Industry gets time and flexibility.
2) Environmental groups get enhanced environmental results.
3) Regulators get a more normal, standardized process putting less
strain on resources.
O Although not as basic as the above three changes, two additional concerns
should also be addressed in the new technology innovation provision.
1) There should be requirements that will ensure that industry will do
its very best to assure permanent attainment of the enhanced
environmental results.
2) There should be provided certainty of reduced noncompliance
penalties if a good-faith effort unexpectedly fails.
Some of the Important Finer Points Within the Proposed Legislation
O The provision provides for a permit modification rather than a "waiver" for
a couple of reasons. First, procedures already exist for permit modifications,
whereas new procedures would have to be established for waivers. Second, in
reality the limits are not actually being waived but modified. So "modification" is
a more accurate term to use in this context.
O While the provision includes control technology and recycling as well as pollution
prevention, the Industrial Pollution Prevention Project (IP3) study of this subject
area found that industry is more likely to use a provision like this for pollution
prevention measures than for control technologies. Therefore, the primary effect
of the provision will probably be to promote innovative pollution prevention.
O Although the term "innovative" is not defined (that should be left to the
regulations), the sense of the provision implies a relatively broad definition of
"innovative." For example, there is no requirement that the innovative process
or technology has to be previously undemonstrated. Further, there is no
requirement that the process or technology has to have industry-wide application.
Criteria like these are problematical in interpretation and therefore do not fit a
provision that seeks to be simple and effective. If the objective is truly to foster
pollution prevention, the provision has to be conducive ~ not problematical or
restrictive.
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O The provision applies to both new sources and existing sources and to
industries both with and without effluent guidelines.
O Only for enhanced environmental results is a modification granted. For
example, the modification is not granted for simply lower-cost technology. The
technology must produce enhanced environmental results.
O Only an industry that is within the time period not exceeding three years
beyond its compliance date can use this provision.
O The maximum period of the modification (i.e., three years from the date for
compliance) is actually six years from promulgation of the standards.
O EPA is given the authority to establish predefined reduction parameters, as
conditions to the modifications, but is not required to do so. Therefore, EPA
has flexibility to decide how many of the reduction conditions to establish and
even has the flexibility not to establish any of them, if it so chooses.
O Establishing the predefined reduction parameters should not be a resource-
intensive task. If done, it will probably be done in a regulatory document
other than the effluent guidelines.
O AH water quality standards of receiving waters are always met — no matter
what. Industry is never allowed to violate them. (Similarly, conditions in a
POTW's permit are never allowed to be violated by indirect dischargers under this
provision.)
O The interim limitations are not burdensome ones that would require an
industry to do something extra. They are either the water quality-based
limitations which the source must meet in any case or previously effective
technology-based limits which — if there were such limits for that industry — the
source is already meeting.
O The period of the modification can vary by facility, depending on the situation;
the predefined reduction parameters can vary by industry.
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O Because enforcing against the enhanced environmental results at the end of the
period of the modification could be a strong disincentive for this provision, only
the originally applicable standards will be enforceable at the end of the
period of the modification. But the provision requires strict monitoring of
progress during the period of the modification with the intent that permanent
attainment of the enhanced environmental results, going beyond the
enforceable standards, will be assured. Regulations for this provision could
require (as part of the permit) a timeline of steps to be taken to demonstrate
adequate progress. A deviation from that schedule of progress would result in
termination of the modification.
O The source will always eventually meet or do better than all applicable
standards, while still preserving the other gains.
O The good-faith effort reduction in penalties can vary with the capital cost loss
sustained by the facility, or other factors.
The "Bottom-Line" Benefits of the Proposed Legislation
O The use of pollution prevention and innovative technologies will increase
significantly.
O There will be greater protection of the environment over time.
O The normal rulemaking process for effluent limitations may be shortened
because, with the regulatory flexibility offered by this provision, there may well
be less litigation from industry and environmental groups over the issued
limitations, This would enable more effluent guidelines to be promulgated
quicker, resulting in cost savings to all the litigants and greater environmental
protection.
NOTE: While it would be desirable to have a reauthorized Clean Water Act containing
this proposed provision, the key concepts embodied in this proposed provision are
probably still implementable even if there is no reauthorized Act or no statutory
change.
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9. International P2 Case Studies
(International (Non-U.S.) Industrial Pollution Prevention (EPA-820-R-94-005) )
This compendium of over 200 case studies describes various pollution prevention technologies
that have been developed and used by industries in different countries around the world. The
case studies come from over 20 countries outside the United States.
The IP3 task which produced this compendium had four parts:
gather all available information on P2 measures implemented by industries in
other countries, which had not been previously gathered;
put all this information into the form of case studies;
compile all the case studies into a hard-copy compendium; and
put all the case studies into electronic files so that they are accessible to all
interested parties.
This is the hard-copy compendium. It was prepared by the IP3 to provide interested parties with
easy access to non-U.S. pollution prevention case studies.
Value
EPA, U.S. industries, and industries around the world can learn from what industries in
other countries are doing. This compendium can be helpful to plant designers, managers,
and regulators around the world who are searching for creative ways to accomplish
further pollution prevention.
Major Findings and Conclusions
The compendium includes many countries' experiences related to a variety of pollution
prevention concepts and technologies.
Before being included, all of the international case studies were reviewed to ensure
conformity with U.S. EPA's concept of pollution prevention, i.e., the multi-media
approach to protecting the environment that involves the use of processes, practices, or
products that reduce or eliminate the generation of pollutants — before recycling,
treatment, or disposal. (For this compendium, only source reduction or "closed-loop"
recycling was considered to be pollution prevention.) Over 200 passed that test and were
included in this compendium.
The information for the case studies came from a variety of sources: United Nations
Environment Programme (UNEP), Organization for Economic Cooperation and
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Development (OECD), embassies and government environmental offices, proceedings
from various international conferences, trade journals, and assorted contacts abroad.
All information obtained was reviewed to ensure that case studies included in this
compendium (and added to electronic files) would be of interest and would provide
sufficient detail to be useful to intended audiences. In some cases, materials had to be
translated into English before being included.
Typically, each case study summarizes:
the technology used
its application
the status of the technology's development
commercial availability
investment and operating costs
cost savings
payback periods
feedstocks utilized
wastes produced
pollution reductions achieved
regulatory issues
any startup or implementation problems encountered
contact name, address, and telephone number
The over 200 case studies are organized by industrial category in the compendium. There
are 20 industrial categories, such as electroplating, chemical manufacturing, pulp and
paper, petroleum refining, textiles, etc.
While most of the case studies demonstrate success stories, examples of failed efforts
(and the reasons for their failure) have also been included, because there is something to
be learned from failure as well as successes.
As indicated above, the case studies compiled for this hard-copy compendium were also
put into the electronic files of the Pollution Prevention Information Clearinghouse (PPIC)
and into the International Cleaner Production Information Clearinghouse (ICPIC) so that
they will be available electronically to all interested parties. Appendix A of the
compendium provides a reference guide to both the PPIC and the ICPIC.
Finally, the compendium includes a very helpful keyword index. The index lists the
keywords included in the case study abstracts with citations indicating the pages on
which each keyword appears.
[NOTE: Subsequent to EPA publication in 1994 of this hard-copy compendium, the
United Nations Environment Programme (UNEP) in 1995 put this IPS compendium
on computer diskette for distribution around the world!]
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10. New England Demonstration Project
(The Merrimack Project (EPA-820-R-95-004) ) [a joint report written by MA and NH]
The IPS conducted Demonstration Projects in four different geographical regions across the
nation. The purpose of these regional pilot projects was to:
demonstrate different specific aspects of the pollution prevention approach;
gain new insights from the demonstrations that will be useful to both industry and
EPA in furthering pollution prevention;
actually prevent pollution at real-world locations; and
initiate and establish ongoing pollution prevention activity and institutions that
will continue on their own long after the IPS demonstration is over.
One of the four IPS Demonstration Projects was in New England. Named the "Merrimack
Project," it sought to demonstrate how two states (Massachusetts and New Hampshire) can work
together to bring about pollution prevention in the industries along a commonly-shared river (the
Merrimack River).
Value
Federal and state policy makers can learn from the experiences of these two states as they
conducted this joint venture. The experiences are especially full of insights because the
two states were so different institutionally.
Industry can learn from the industry case study examples developed in this demonstration
and from seeing how a regional "self-help" network of businesses became established to
promote P2 within its sphere of influence.
Major Findings and Conclusions
The Merrimack Project demonstrated:
O Two states, even when very different institutionally, can successfully work
together to bring about P2 in the industries along a commonly-shared river.
The two states jointly exchanged frequent visits to one another's state
offices to share ideas/information, learn from one another's experiences,
plan together, and build personal relationships among the staff.
The two states jointly conducted a series of industry-specific P2
workshops for Merrimack River industries.
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The two states jointly held two major P2 conferences: an outdoor (under a
tent) conference on a bluff overlooking the Merrimack River and another
conference in Lowell, a city on the Merrimack River.
The two states jointly performed P2 technical assistance during a number
of industrial site visits.
The following is quoted from the conclusions (page 64) of the joint report
that the two states wrote on the Merrimack Project:
" This project has been essential in helping the New Hampshire
Department of Environmental Services jumpstart the process
of institutionalizing pollution prevention. Through this project
the department has been able to experiment with different
approaches and frame the questions which need to be addressed.
The project has also provided a forum to identify opportunities and
barriers in implementing pollution prevention in a regulatory
agency.
Working collaboratively with staff from the MA Office of
Technical Assistance has been a very satisfying and rewarding
experience. This project has proven that agencies from two
states can work together to accomplish common goals and
objectives, even though their program structures and
regulatory status may be different. Likewise, working with EPA
staff on the Merrimack Project has been very beneficial. EPA staff
provided flexibility as well as guidance, both of which were greatly
appreciated. Establishing new relationships and forming
innovative partnerships is what this project was all about. It
seems almost certain that the relationships that have been
established will continue well beyond the life of the Merrimack
Project...."
The Merrimack Project achieved:
O Greatly increased P2 implementation in the Merrimack River watershed.
As many as 91% of the companies that were provided P2 information
during the Merrimack Project actually implemented P2.
O Measurement of actual P2 results brought by the Project.
Sixty-two companies in the Merrimack watershed were visited with P2
technical assistance by Merrimack Project staff during the project.
(Almost 40 pages of the states' joint report on the project are devoted to
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describing in detail these site visits and what was accomplished.) Data on
actual P2 results were gathered concerning 49 of the companies, (These
data are detailed in the states' joint report.)
O Environmental improvement to the Merrimaek River and cost savings to
Merrimack River industries.
As a result of the Merrimack Project, already over 1.7 million pounds of
toxic substances have been eliminated — with a savings of over SI.9
million to industry. (NOTE: As detailed in the states' joint report on the
Merrimack Project, these figures are based on reported data that were
tabulated very conservatively, e.g., "thousands" = 1,000.)
Some companies achieved P2 but did not produce data on money saved or
pounds eliminated. These companies included:
A machine shop that ceased wastewater discharges with vacuum
distillation.
A manufacturer that reduced water use 87% and drummed waste
40%.
A semiconductor company with a closed-loop process.
Four electronic components manufacturers that eliminated TCA.
Two facilities that eliminated nuisance odors.
In addition, several companies, while not reporting pounds eliminated or
dollars saved, did improve compliance, e.g., by establishing proper
hazardous waste storage practices.
O Widespread interstate promotion of P2.
The project conducted over 20 major workshops and over 100 public
events promoting P2.
(This was in addition to the over 200 on-site assessments of P2
opportunities conducted by the project at over 60 industrial facilities
throughout the Merrimack River watershed.)
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O Establishment of new and lasting institutional commitments to P2.
New Hampshire
As a result of the Merrimack Project, the State of New Hampshire
established a technical assistance program known as New
Hampshire's Pollution Prevention Program (NHPPP). Prior to the
Merrimack Project, the State of New Hampshire did not have any
formal technical assistance program providing or promoting toxics
use reduction or pollution prevention.
The following is quoted from the states' joint report on the
Merrimack Project:
" It must be recognized that at the beginning of the project
NH staff had a difficult time convincing companies that it
was safe to consult with them The fact that NH's
technical assistance personnel convinced 14 companies to
let them come on site was therefore a substantial
accomplishment. NH's follow up resulted in a vast
majority of companies that worked with NHPPP stating
that they were very pleased with the service given to them
and that they would not hesitate to call on the program
again or recommend the program to other businesses."
The following is quoted from EPA Region 1 (New England)'s.
report (see 11. on page 32 below) on the Merrimack Project:
" As the Merrimack Project gained popularity, the NHPPP
was increasingly being asked to perform on-site
assessments, organize workshops, train staff, and respond
to informational requests....Within two years, NHPPP had
become recognized throughout New England as an
organization possessing the ability to identify and
characterize pollution prevention opportunities."
The following also exemplifies the extent of NH's commitment:
- NH held a Solvents Bazaar, at which 55 companies had the
opportunity to bring parts needing to be cleaned to be
cleaned by alternative products.
- NH held a P2 conference in 1993, attended by 45
Merrimack Valley companies.
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- NH held a P2 conference in 1994, attended by 58
Merrimack Valley companies.
- NH successfully established a P2 clearinghouse of
information on new and innovative technologies, products
and vendors, fact sheets, and case studies and made it
available to businesses and industries. It has also
successfully developed and instituted procedures for setting
request priorities and disseminating information.
The Merrimack Business Environmental Network (MBEN)
As part of the Merrimack Project, MBEN was formed. It is an
ongoing forum of businesses committed to P2, to environmental
compliance, to interacting with government agencies, and to
mutual self-help. MBEN conducted monthly meetings for its
members, at most of which there have been presentations or
discussions of environmental requirements and P2. (One of the
purposes of the organization was to change the focus of the
delivery of P2 information and the P2 message, so that it would
come from business, not just government.)
MBEN, with MA and NH, sponsored two major regional
conferences, each of which garnered attendance of about 100.
There were about 30 committed, active members of MBEN from
the business community who came regularly to all MBEN
meetings, with more than 80 registered as members, who came
principally to MBEN conferences. All members pay dues and sign
the MBEN mission statement, which reads as follows:
"The Merrimack Business Environmental Network is a coalition of
businesses, agencies and associations which is committed to a
shared concern for the Merrimack Valley, its rivers, and the
Valley's quality of life. This Association has made a long-term
commitment to seek and implement solutions to promote pollution
prevention through improved management and technology, while
enhancing the economic viability of the business community."
MBEN generated a good deal of interest in other regions, who
sent in requests for information on how to create similar
organizations. To enable the network to reach a larger
audience, MBEN became incorporated as the Northeast
Business Environmental Network (NBEN) in September 1994.
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A focus of NBEN in 1995 has been on providing opportunities for
business and government to work together on regulatory
improvement. Bylaws for NBEN stress the nonpartisan nature of
the group and prohibit it from engaging in political lobbying. The
most recent NBEN conference was in May 1995, and engaged the
attentions of the highest government officials in New England.
(Details of the May conference are included in the Appendices to
the states' joint report on the Merrimack Project.)
The enthusiastic participation of businesses in MBEN, now
NBEN, accomplishes one of the Merrimack Project's basic
purposes: to form a continuing, collaborative, working
commitment to P2 by all the stakeholders.
All the publicity that MBEN received from the media resulted in
numerous newspaper and magazine articles including one in
Pollution Prevention Review (a copy of which is included in the
Appendices to The Merrimack Project report.)
Based on insights gained from the Merrimack Project, the two states' joint report on the
Merrimack Project concludes with 21 policy recommendations, such as:
O U.S. EPA should re-evaluate regulatory program measures of success. Focus
should be placed on actual pollution reductions and increases in compliance rather
than number of inspections performed or enforcement actions taken.
O More use should be made of the established POTW-industry relationship to
promote P2. Often a POTW Pretreatment Coordinator already has an established
working relationship with the industries he/she regulates. This relationship
provides an excellent opportunity to further the goals of P2.
O U.S. EPA should encourage and support new and innovative partnerships.
Through the Merrimack Project some new and unique partnerships were formed
between state and private entities: The Merrimack Business Environmental
Network (MBEN) and the NHDES Merrimack River biomonitoring project are
two examples. Partnerships like these are a very effective way to maximize
resources while promoting pollution prevention.
O Geographic initiatives especially should be encouraged and supported.
Pollution and natural resources do not respect political boundaries: Watershed-
based projects such as the Merrimack Project and the Merrimack River Initiative
provide an ideal opportunity to transcend political boundaries and rally around a
common environmental cause.
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O U.S EPA should review categorical discharge limits—and reset them
according to what known P2 technologies and practices can economically
achieve. Rachet limits down when technologically and economically feasible,
according to frequent reviews.... The pressure of regulation drives companies
toward P2. A certain sector does P2 because they are well informed and
understand its value. A larger sector does P2 because they have to.
O Enforcement activities should require or encourage P2 and P2 reporting.
Compliance orders should never simply order control technologies, but should do
one of two things instead: either require P2 investigations or provide optional
methods for coming into compliance.
O Regulatory agencies should reorganize to the extent that functional activities
can be coordinated with the goal of avoiding cross-media transfers — in
permitting, inspections, enforcement, and in all policy formation and
statements.
O Water quality and discharge data should be made as accessible as TRI data
are.
O The formation of self-help groups of POTW personnel should be encouraged.
Merrimack Project staff were impressed by the formation of the Massachusetts
Pretreatment Forum, a discussion forum of and for POTWs in Massachusetts. It
served a very useful function in keeping POTW officials up to date on P2 in the
Merrimack Project. This group should be regarded as a model for encouraging
the establishment of similar groups in other parts of the nation.
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11. New England Demonstration Project: EPA Region 1 Report
( The Merrimack Project: A Report Bv EPA Region 1 fNew England^ (EPA-820-R-95-005))
[See the introduction under 10. on page 25.]
This EPA Region 1 (New England) report presents Merrimack Project results, implications, and
follow-on next steps ~ as seen from EPA Region 1 (New England)'s perspective.
Value
Government policy makers can learn from knowing how EPA's regional office views the
results, implications, and follow-on next steps of the Merrimack Project.
Major Findings and Conclusions
The report presents the following results of the Merrimack Project:
O As an interstate effort, the project tested and demonstrated that two states,
even with technical assistance programs that are very different
institutionally, can successfully work together to provide technical
assistance to industries along a commonly shared river.
O The Merrimack Project also demonstrated that a technical assistance
program can be successfully structured and implemented under either a
regulatory or non-regulatory organization.
O The Merrimack Project demonstrated the value of publicizing the potential
for pollution prevention opportunities.
O The Merrimack Project achieved both cost savings to industry and
environmental improvement to the Merrimack River.
O Positive experiences with the project's workshops, technical assistance,
kept-confidences ~ combined with a desire to continue an intensified
ongoing level of communication on an industry-wide basis ~ led involved
Merrimack industries to work with the two states to form a Merrimack
Business Environmental Network (MBEN). In turn, MBEN has
mushroomed into a Northeast Business Environmental Network.
O The Merrimack Project also showed how Total Quality Management
(TQM) techniques can be used by a state agency as a tool in creating a
pollution prevention program and in implementing pollution prevention
technical assistance to industry.
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(The New Hampshire Department of Environmental Services used TQM
while constructing the New Hampshire Pollution Prevention Program
(NHPPP). Program commitments were evaluated against existing
resources. The procedure involved an investment and disinvestment
process using TQM. As a result, resources and job functions were shifted
within certain programs in order to create the NHPPP.)
The report presents the following implications of the Merrimack Project:
O Because the project has demonstrated that environmental compliance can
be obtained in conjunction with traditional enforcement related activities
as well as by using technical assistance independently of enforcement, the
project has highlighted that technical assistance should never
necessitate the suspension of enforcement, or disinvestment in
enforcement.
O The project has also verified that P2 technical assistance is an effective
tool for encouraging and achieving environmental compliance.
O The following is quoted from Region 1 (New England)'s report on the
Merrimack Project:
"The Merrimack Project experience has overcome the deep-seated
mindset that EPA, as well as state environmental agencies, must serve
solely as a regulatory agency, taking a "hands off approach to
offering technical assistance....The Merrimack Project resolved many
myths on whether or not a regulatory organization could successfully
implement pollution prevention."
O The Merrimack Project produced numerous examples of "how to
methods" of integrating pollution prevention and technical assistance
programs into enforcement related activities, while taking into
consideration management's concerns.
The following is quoted from Region 1 (New England)'s report:
"The project has produced a network of valuable technical assistance
resources that can assist management and staff. As a result, the
project has increased the ability of each and every person at EPA
Region 1 (New England) to access this information more readily than
ever....The project also provides us in EPA Region 1 (New England)
with additional insight on various techniques that we might consider
when promoting or implementing pollution prevention."
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The report concludes by presenting next steps for EPA Region 1 (New England)
- hereinafter referred to as EPA - New England - to take in building upon the
Merrimack Project:
O Support P2 technical assistance — both separate from and in conjunction
with water quality evaluations, permit writing/negotiations, and
compliance.
O Strengthen the performance measures for compliance and enforcement
activities to include not only the numbers of permits, inspections, and
enforcement actions but also measures of environmental results.
O Undertake three proposed EPA - New England FY95 P2 initiatives. (Each
initiative is specified in the report on the Merrimack Project.)
O Support the development of local discharge limits that are based on best
available technology which recognizes and credits P2 technology.
O Support and involve POTWs in P2 technical assistance by assisting them
in negotiating implementation schedules with their respective industrial
users.
O Provide incentives to stimulate development and application of new
technology to achieve P2 and more cost-effective measures to meet limits.
O Support provisions in CWA reauthorization to incorporate more P2 in
permitting. In the meantime, take advantage of every opportunity to
integrate P2 into permitting, e.g., implementation measures, compliance
schedules, outreach, and reporting.
O Develop integrated data management systems to...make it possible to
target P2 technical assistance to the most critical industrial facilities. (The
Merrimack Project revealed that such a system was lacking and would be
helpful if it existed.)
The report then describes the newly-formed New England Environmental
Assistance Team (NEEAT) and what it will be doing.
The report ends with the following sentence:
" In sum, the Merrimack Project has provided important experience
with assistance tools, partnerships, and geographic focus that now
forms EPA - New England's own assistance efforts.11
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12. New England Demonstration Project: Building Partnerships for P2
( The Merrimack Project: Building Partnerships to Prevent Pollution in a Watershed (a summary
report published by the Commonwealth of Massachusetts's Office of Technical Assistance) )
[See the introduction under 10. on page 25.]
This Building Partnerships report is a summary report of the IP3's New England Demonstration
Project, i.e., the "Merrimack Project," from the Commonwealth of Massachusetts^ perspective.
Value
Federal and state policy makers can learn from the experiences and insights that
Massachusetts gained from the IP3's "Merrimack Project."
Major Findings and Conclusions
The objectives of the Merrimack Project were met. Those objectives were:
O to promote pollution prevention as an ethic by working directly with businesses in
the Merrimack watershed;
O to identify opportunities to incorporate pollution prevention into regulatory
practices and policy, and to coordinate P2 efforts with regulatory agencies;
O to encourage industry, regulators, and others to view pollution prevention as a
means of achieving both environmental protection in the watershed and economic
health for local companies.
Among the project's results:
O Pollution prevention outreach and education efforts, including workshops for
businesses (several tailored for specific industries) and training sessions for
POTW and regulatory staff, resulted in increased requests by industry for P2
technical assistance. Massachusetts's Office of Technical Assistance staff worked
with more than 55 companies in the Merrimack watershed during the project.
O Ten Massachusetts companies together eliminated nearly 1.7 million pounds of
toxic pollutants, and 18 companies saved $1.85 million by implementing P2
strategies. Several other companies also reported reduced pollution and cost
savings, but did not have specific numbers. The total amount of pollution
prevented and money saved is believed to be much greater than the numbers
reported.
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O A group of regional businesses that began meeting informally through this project
with government officials and environmental advocates to exchange information
about P2 has incorporated as a nonprofit organization called the Northeast
Business Environmental Network (NBEN). A nonpartisan network dedicated
solely to helping its members improve their environmental performance in
manufacturing operations, NBEN has been recognized as a model business-
government partnership.
O Training and informational exchanges between Massachusetts's Office of
Technical Assistance (OTA) and Massachusetts's Department of Environmental
Protection (DEP) that began with this project have evolved into an ongoing
exchange between the agencies, including company referrals by DEP to OTA's
technical assistance services.
O Information exchange between Massachusetts and New Hampshire environmental
agencies resulted in the conduct of joint public events, cooperation in the
formation of NBEN, and a unified message promoting pollution prevention in the
watershed.
In accord with the theme contained in its title, "Building Partnerships," this report by
Massachusetts describes in detail three aspects of the IPS's Merrimack Project:
working with POTWs
— The project conducted P2 training for POTW personnel.
— Working with POTWs, industry-specific workshops and conferences on
P2 were organized. Invitations were mailed out by POTWs to dischargers
in their area. Approximately 200 attendees learned about specific P2
strategies and technologies, and heard businesses with P2 success stories
tell how they saved money or improved quality while avoiding pollution.
Target industries for the workshops were selected by analyzing POTW
permit lists and consulting with POTW operators. POTWs reported
positive outcomes from their involvement in the workshops. (Those
outcomes are presented in the report.) The Lowell, Greater Lawrence,
Newburyport, and Haverhill POTWs, for example, have continued the
practice of holding public events to educate their dischargers, and requests
have come in from other POTWs in the state to conduct similar events.
— POTWs gained a better understanding of and appreciation for pollution
prevention as a means of helping businesses remain in compliance with
discharge limits, or eliminate the use of certain chemicals altogether.
- The Merrimack Project gave POTW officials a chance to help dischargers,
as opposed to simply enforcing against them.
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~ POTWs shared strategies with each other. For example, the Newburyport
POTW told other POTW officials how they have incorporated into some
permits a requirement that dischargers report chemical purchases to the
POTW; the Greater Lawrence POTW shared how it has added P2
questions to its full inspection forms.
~ The Merrimack Project increased POTWs' interaction with each other,
with industry, and with the state, leading to improved and effective
communications and relations.
working with businesses
~ The report addresses working in partnership with 58 companies during the
Merrimack Project, including electronics manufacturers, machine shops,
web coaters, metal platers/finishers, printers, printed circuit board
manufacturers, spray paint contractors, the plastics industry, adhesive
manufacturers, textiles, paper, furniture, leather products, wood stain,
Pharmaceuticals, and other specialty products.
~ The report also describes the Merrimack Project's establishing the
Merrimack Business Environmental Network (MBEN) — which has
expanded to become the Northeast Business Environmental Network
(NBEN) — and its growing influence.
- coordination with regulatory agencies and programs
-- An objective of the Merrimack Project was to coordinate with regulatory
programs, both to increase regulators' awareness and understanding of P2
opportunities and to better define and enhance the relationship between
regulation/enforcement and technical assistance. In addition, the project
sought to identify opportunities and barriers to incorporating P2 in the
work of regulatory agencies and to test new initiatives.
MA OTA adopted the strategy of establishing training exchanges and
referrals with the MA DEP (the state's environmental regulatory agency).
At the same time, MA DEP made pollution prevention a top priority and
has reorganized accordingly.
— As part of the Merrimack Project there was P2 training for EPA inspectors
and managers, MA DEP inspectors and managers, POTW pretreatment
coordinators, board of health agents, and audiences made up of regulatory
officials of various agencies and authorities.
-- The concept of P2 technical assistance initially raised several concerns
among regulatory officials. These concerns included:
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that resources would be diverted from enforcement or that
enforcement would somehow be diminished;
that the touting of P2 could seem to mean a denigration of
pollution control;
that if inspectors made suggestions concerning P2 activities,
companies would interpret these suggestions as commands.
During the Merrimack Project, MA OTA addressed these concerns with
the following points:
Technical assistance can be provided with a minimal devotion of
resources, or with the incorporation of the function into existing
programs, or with the use of new resources (e.g., based on fees).
Assistance should not replace enforcement but should complement
it, because strong enforcement is of paramount importance — it is
the major reason why companies implement P2 or seek technical
assistance. Complementing enforcement with assistance improves
the relationship between government and the regulated community.
Assistance is the appropriate tool for interacting with those
members of the regulated community who want to do the right
thing and simply need a better understanding of the requirements
and options.
Although the hierarchy means prevention should be exercised first
and foremost, it must be recognized that when it is not
implemented, recycling, treatment, or other appropriate
management of wastes already generated is still preferable to
certain other alternatives. It has been necessary to affirm on many
occasions that pollution reduction is a desirable activity, even if it
is not prevention.
Inspectors could and should refer companies to a technical
assistance agency for specific help, while talking about P2 in
general to indicate the priority the agency places on the approach.
Inspectors can also adopt the strategy of asking questions in lieu of
making commands, because asking questions is a nondirective
method of illuminating P2 opportunities and pointing a company in
the right direction and denotes respect for the regulated company
arid can enhance the relationship between the company and the
regulator. (In addition, dialogue concerning the process educates
the inspector, which can improve regulatory practices.)
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~ The Merrimack Project also confirmed the importance of seeking to tailor
enforcement strategies to encourage P2, through measures such as:
waivers, extra time, penalty mitigation, and elimination of roadblocks to
process changes. MA OTA staff frequently worked with companies
facing short timeframes to address violations. Conventional end-of-pipe
control equipment is readily available. To supplant the control technology
with a preventive technique may only be possible if the company has the
time for investigation and trial.
Coordination between MA OTA and MA DEP has now evolved to mutual
exchange. For example, DEP now sends copies of all Notices of
Noncompliance to OTA, and included in these notices is language
encouraging the recipient to contact OTA for help. Inspectors often
recommend OTA's services to companies.
Among the report's stated conclusions are the following:
The results of the Merrimack Project demonstrate that —
O industry and regulatory agencies are very receptive to education and
information programs about P2, and can work together effectively to
educate others about specific P2 strategies and the possible benefits;
O businesses that implement P2 can reduce the amount of toxic byproducts
reaching the environment and at the same time realize significant cost
savings;
O many businesses are very concerned about environmental protection as
well as the bottom line and are willing to share successful P2 strategies
with other companies.
The lasting results of the Merrimack Project include ~
O many companies in the Merrimack watershed adopting P2 strategies, and
changing forever the way they approach the environmental issues relating
to their operations;
O the establishment of the Northeast Business Environmental Network
(NBEN), a model nonpartisan business-government network dedicated to
promoting P2 as a means of achieving environmental protection and
maintaining economic competitiveness, and providing increased sharing of
information among businesses and between businesses and government
and environmental organizations;
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O an improved understanding of P2 opportunities by regional POTWs and
MA DEP inspectors, and collaboration among POTWs, MA DEP, and MA
OTA in promoting P2 as the preferred approach to industrial
environmental problems;
O the identification of opportunities to incorporate P2 into environmental
regulations and policy;
O increased understanding that environmental improvements need not be at
the expense of economic progress;
O increased awareness by businesses in the Merrimack region of the
importance of local natural resources; and
O increased awareness by governmental officials of the point of view of
businesspeople who wish to be environmentally friendly.
The Appendices to the .report contain a published article on MBEN (later to become
NBEN) and 15 "true tales" of technical assistance conducted during the Merrimack
Project. The "True Tales of Technical Assistance" are presented to assist anyone wishing
to understand in detail how a P2 technical assistance program actually works.
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13. Nebraska Demonstration Project
(Pollution Prevention at an Aging Midwestern Manufacturing Facility (EPA-820-R-95-009))
[See the introduction under 10. on page 25.]
One of the IPS's four demonstration projects was in Nebraska. The goal of the Nebraska project
was to demonstrate the adoption of pollution prevention measures at a rural and aging metal
products manufacturing facility.
Value
Industry can learn from the thorough — and very detailed — P2 opportunity assessment
and the P2 implementation experiences of this metal products manufacturing case study.
Major Findings and Conclusions
O Waste disposal at this facility had resulted in potential problems, especially to
surface and ground water resources in the area. The economic viability of the
company depended on addressing the pollution problem and reducing pollution
control expenses.
O In conducting the thorough and very detailed P2 opportunity assessment,
emphasis became focused on those areas where the impact on reducing the total
pollutant load would be the greatest. Those areas were the electroplating, hot-dip
galvanizing, and the painting lines as well as the tube mill production process.
O For each of those four areas, specific P2 process and/or materials changes were
recommended and are described in detail in the project report. Besides the
technical details, the project report also presents the pollution load
reductions, financial costs, and payback periods.
O One of the major considerations in making P2 recommendations to this company
was that the facility was old and not very profitable. Therefore, recommendations
for process and operational modifications resulting from the P2 opportunity
assessment had to meet critical payback periods. The good news from this project
is that the P2 recommendations that have been implemented thus far have
provided quick payback and have truly revitalized the company!
O The company is very pleased with their adoption of P2. The P2 process and
materials changes have not only increased company profitability but have
significantly improved product quality as well! For example, the level of rust
protection in the facility's products increased up to 1000%, which delighted the
company because numerous claims had been made against the company in the
past because of corrosion of some of its products.
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O The environment has also greatly benefited from the company's adoption of
P2.
O The project also developed longer-term recommendations for the facility in
addition to the shorter-term recommendations that have already been
implemented. Those longer-term recommendations are also described in the
project report. The company is currently well on its way in implementing the
longer-term recommendations. Implementing P2 and thereby improving
facility performance and profitability will continue on into the future at this
manufacturing site in Nebraska.
O Finally, while the primary goal of this project was to demonstrate the adoption of
P2 at a rural, aging, not-very-profitable metal products manufacturing facility, a
secondary goal of the project was to demonstrate how to involve a nearby
university ~ in this case, the University of Nebraska at Lincoln - in a
cooperative and collaborative approach to promoting P2 implementation.
The approach involved industry, the university, and EPA. (EPA (i.e., the IP3)
provided "seed money" in the form of a small grant to the university, the
university provided matching funds, and the industry agreed up-front to work
closely with the university during the P2 opportunity assessment and fund the
recommended P2 implementation.) The project demonstrated it to be an excellent
approach. It proved to be a very effective way to bring about P2
implementation and each party gained something from the collaboration.
O Articles on this demonstration project have been published in Environmental
Solutions, as well as in Water Science and Technology and the proceedings from
several different conferences where this project has been presented.
14. and 15. Nebraska Demonstration Project: Technical Reports #1 and #2
( #1: Pollution Prevention in the Commercial Sector: Waste Stream Assessment in the Metal
Finishing Industry (available from the University of Nebraska-Lincoln libraries) )
(#2: Waste Minimization Opportunities for the Electroplating Industry (available as above) )
Technical Report #1 is a lengthy, highly detailed, very technical report on the P2 opportunities
for the metal finishing industry — specifically the galvanizing, painting, and tubing fabrication
processes. Technical Report #2 is a lengthy, highly detailed, very technical report on the P2
opportunities specifically for the electroplating process.
Value
Those who need to know all the technical details and all the technical rationale behind the
P2 measures for those four metal finishing processes can learn them hi these two reports.
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16. Southern California Demonstration Project
( Pollution Prevention at Industrial Laundries: A Collaborative Approach in Southern California
(EPA-820-R-95-012) )
[See the introduction under 10. on page 25.]
One of the IPS's four demonstration projects took place in Southern California. Its purpose was
to demonstrate a collaborative approach to promoting pollution prevention, i.e., how enhanced
communication and coordination among federal, state, and local regulatory agencies in a region
of a state can be conducted to promote P2 within a selected industrial sector. The industrial
sector chosen for this demonstration was industrial laundries.
Value
Federal, state, and local policy makers and regulators can learn from this interagency,
multi-media demonstration of enhanced communication and coordination among the
regulators and with the regulated. Industry can learn from the P2 opportunity
assessments and P2 options developed in this demonstration.
Major Findings and Conclusions
O The large number of federal, state, and local laws, regulations, agencies, policies,
and enforcement practices regarding toxic pollutants is often overwhelming and
sometimes conflicting, confusing, and frustrating to businesses. To be most
effective, P2 must be promoted through the unified efforts of all the regulators.
O All of the laws and regulations currently in place in California that create an
incentive for industry to engage in P2 were collected, analyzed, and summarized.
A report was produced, A Summary of the Regulatory Incentives for
Pollution Prevention.
O All agencies (federal, state, and local) with requirements affecting multi-media P2
in Southern California were formally invited to participate in this demonstration
project. Twenty-four different agencies attended and participated in the project
meetings and formed the interagency multi-media team to demonstrate a
collaborative approach to promoting P2 implementation at industrial laundries.
O The project produced a Report on Areas in Need of Coordination which
identifies and discusses specific air quality, water quality, solid/hazardous waste,
and other regulatory programs that need coordination in order to have a unified
approach to pollution prevention in Southern California.
O To industrial laundries, the area most in need of coordination is resolution of
the "shop towels as hazardous waste" issue.
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O Detailed facility assessments were conducted at industrial laundries
throughout Southern California (see 17. Southern California Demonstration
Project: Technical Report below), and the findings and results of these
assessments were presented at a big workshop held in June 1993.
O The June 1993 workshop was developed by the interagency multi-media
team as a blueprint for future workshops. The workshop took a multi-media
approach and was conducted in partnership with the industrial laundries.
Presenters at the workshop were from regulating agencies and industrial laundries.
O Discussions with industrial laundry operators and management during facility site
visits and during the project meetings revealed several key points, including:
Industrial laundries have coped with the problem of non-compliance with
local toxic organics and oil and grease limits by discontinuing the
laundering of shop towels and shop uniforms at the facilities subject to
stringent limits. Instead, the materials are taken to facilities not subject
to stringent limits.
The usual discharges to the environment from industrial laundries are
washwater draining to sewers, solvents from fabrics evaporating to the air,
filter cakes taken to landfills, and oil from water/oil separators taken to
recyclers. The facility assessments confirmed that, while there are sources
of pollutants internal to the laundry (e.g., detergent residues, truck
cleaning, etc.), the bulk of pollutants found in laundries' discharges
originate in the material received from customers. Toxic organic
compounds and oil and grease were the two pollutants most causing the
industrial laundries to be in non-compliance with environmental
regulations. The greatest contributor of those two pollutants were
shop towels (and rags and uniforms) impregnated with solvents and oil.
Industrial laundries are subject to conflicting, single-media regulations
and inconsistent requirements which result in overall reluctance to take
the "risk" of pollution prevention innovations.
O The project identified 16 specific pollutants of concern for industrial laundries
and probable sources of those pollutants.
O The project showed that there are P2 opportunities available for both
laundries and their customers. For both, the establishment of and adherence to
a set of best management practices (BMPs), followed by continuous improvement
in searching for ways to minimize the generation of pollutants, is the key. The
project produced a listing of BMPs for industrial laundries and their customers.
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O The Multi-Agency Work Group, recognizing that one of the biggest problems for
laundries and the area of most concern for regulatory agencies is dealing with
shop towels, suggested that P2 options for laundries that process shop towels
could include:
education of their customers on P2 opportunities to prevent shop towel
contamination;
use of BMPs at the customer's site prior to transportation to minimize the
amount of solvent in the material accepted by the laundry for washing; and
use of BMPs for the safe handling of solvent-laden shop towels, which
might include:
requirement of no free liquids
use of the paint filter test (used by some states)
use of a wring test (hard to standardize)
collection containers with mesh bag (to allow settling)
weighing towels and rejecting those above certain weight
centrifuges mounted on trucks
(A more complete and detailed list of BMPs for shop towels, both for the
laundries and for the customer, was produced by the project — along with
two pages of points on why BMPs are important and how they are
beneficial for the laundries. These materials, developed for the
workshops, were disseminated to the laundries and their customers.)
O The interagency multi-media team discussed how two states (Minnesota and
Washington) have resolved the "shop towels as hazardous waste" regulatory issue.
O Besides the importance to Southern California industrial laundries of resolving the
"shop towels as hazardous waste" issue, there also needs to be ongoing
interaction between the local POTWs and the laundries. Laundries want to
know what causes problems for POTWs (e.g., What are their contaminants of
concern? What's hard for them to treat?)
O There needs to be a dialogue and a cooperative effort between POTWs and
laundries to help identify whether or how the laundries' customers are contributing
to POTW problems and what can be done about it. Laundries and POTWs need
to focus on ways of transferring information. It is important also that
laundries and regulatory agencies work cooperatively together in providing
to customers training and periodic retraining in P2 and the use of BMPs.
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O The inter agency multi-media team, in cooperation with management and
personnel representatives of industrial laundries, developed a strategy which
an industrial laundry could adopt for the P2 program:
(1) Make everyone a part of the same P2 team - internal team
members would include laundry operating personnel, staff and
management, distributors and route drivers; external team
members would be the laundry's customers.
(2) Develop best management practices (BMPs) for internal and
external handling of laundry ~ at the laundry and at the customer's
shop. (The project produced a listing of possible BMPs for
laundries and their customers.)
(3) Train and periodically retrain internal staff and customers.
(4) Use route representatives and salesmen to disseminate BMPs and
ensure that these practices are consistently applied in the
customer's shop at pick-up, transfer, and delivery. (The project
produced a written strategy for this dissemination of BMPs to
customers.)
(The workshop held in June 1993 put forth ideas and materials industrial
laundries and regulatory agencies can use to implement this strategy.)
The project concluded the following:
O Any effective P2 program for industrial laundries needs to extend into the
customer's shop. The customer is an integral part of the industrial laundries'
environmental compliance program. (This reality was a major reason industrial
laundries were selected as the industry for this demonstration — because involving
the one industry (industrial laundries) in a P2 emphasis naturally leads to
involving many other industries as well.)
O The transfer of solvents, oils, and other pollutants to towels, rags, and
uniforms by the customer should be considered emissions to the environment
and should be accounted for in the customer's overall emissions.
O A P2 program for customers needs to be applied universally and consistently
to retain competitiveness of individual laundering facilities.
O Industrial laundries' control of emissions from customers to the laundering
facility needs to be done in partnership with the customer - and with the
support of regulators.
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O The challenge for regulators and industry is to find a mechanism, both
regulatory and administrative, to extend P2 beyond the industrial laundry facility
into the customer's shop and incorporate the customer (i.e., the generator of the
pollutants) into the P2 program. The basis for developing such a mechanism
should be a partnership among laundry, customer, and regulator, supported by a
mix of regulatory mandates and incentives.
O The collaboration and cooperation that was instituted by this demonstration
project must continue into the future. Especially with U.S. EPA continuing to
work on developing effluent guidelines for industrial laundries, it is important to
maintain the partnerships established in this project. For example, it is important
to:
continue with the interagency multi-media team meetings with industrial
laundries and local agencies to (1) assess progress in implementing BMPs;
(2) serve as a sounding board for the U.S. EPA's effluent guidelines work
group; (3) work on other existing and emerging issues; and (4) conduct
any issue-specific meetings of value to participants.
have local agencies, with the laundries, jointly coordinate P2 outreach
(e.g., a joint letter from different regulatory agencies emphasizing BMPs)
to the laundries' customers.
continue — as a team — to publicize and disseminate the findings and
materials from the project.
This demonstration project brought together in Southern California all the different
regulatory agencies and industry for the first time — as a team. It provided a
valuable forum to inform everyone of everyone's concerns and put everyone on the
same "wave length." It instituted a new ongoing dialogue among all the regulatory
players. It can serve as a model for how this collaborative, team approach can be
done in other regions.
In summary, the overall message of the IP3's "collaborative approach in Southern
California" is that the best way to get good things done is through partnerships. In
order to be most effective in promoting the implementation of pollution prevention,
we need a sense of partnership among the various regulators, among the regulators
and the regulated, between POTWs and their users, and between industrial
laundries and their customers. This project has demonstrated that these parties can
work successfully together in a spirit of collaboration and cooperation. It is
important that this spirit that has been established in Southern California continue
there and be fostered in other places as well.
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17. Southern California Demonstration Project: Technical Report
( Pollution Prevention at Industrial Laundries: Assessment Observations and Waste Reduction
Options (EPA-820-R-95-010) )
This technical report on P2 opportunities and waste reduction options is based on the detailed
industrial laundry facility assessments conducted as part of the Southern California
demonstration project.
Value
Laundry facility operators and government regulators can learn about P2 opportunities
and waste reduction options; and corporate management of industrial laundries can learn
that - through a strong commitment to an ongoing P2 program involving improved
customer partnerships ~ their plants can achieve significant waste reduction.
(The Institute of Industrial Laundries in its publications has disseminated information
from this report to its members.)
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18. Pacific Northwest Demonstration Project
(Pollution Prevention Assessment and Implementation at a Pulp and Paper Mill in the Pacific
Northwest: Summary Report (EPA-820-R-95-011) )
[See the introduction under 10. on page 25.]
One of the IPS's four demonstration projects was in the Pacific Northwest. Its purpose was to (1)
demonstrate pollution prevention opportunity assessment and implementation at a specific pulp
and paper mill in Tacoma, Washington; (2) develop a model pollution prevention plan for use by
other similar mills; and (3) provide a bibliography of publications related to pollution prevention
for the pulp and paper industry. This demonstration project also showed how P2 can be
incorporated in permit writing and the enforcement settlement process.
Value
Industry and government regulators can leam about P2 opportunities for pulp and paper
mills and can learn from the P2 implementation experience of this Tacoma mill.
Major Findings and Conclusions
The IP3 in cooperation with the Simpson Tacoma Kraft Company and the Washington
State Department of Ecology conducted in early 1992 a study of the opportunities for
pollution prevention at the company's Tacoma mill.
O The assessment identified and evaluated nearly fifty feasible P2 alternatives,
which are listed in Tables 4 and 5 of the assessment report (see 19. Pacific
Northwest Demonstration Project: Simpson Tacoma P2 Plan below). The tables
include a description, estimated pollution reduction benefits, approximate cost,
and suggested priority of each of the P2 alternatives. Cost estimates for each
alternative range from several thousand dollars to several million dollars.
O Recommendations were made to Simpson Tacoma management to develop
an ongoing P2 program and implement near-term and long-term process
modifications to attain P2 benefits.
Seventeen near-term options, for implementation within 1 to 5 years,
were recommended. (See 19. Pacific Northwest Demonstration Project:
Simpson Tacoma P2 Plan below.)
Nine long-term options, for implementation within 5 to 10 years, were
also recommended. (See 19. Pacific Northwest Demonstration Project:
Simpson Tacoma P2 Plan below.)
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O To date, Simpson Tacoma has already implemented many P2 measures and
is in the active process of implementing many more. These include 11 of the
near-term options and 4 of the long-term options. The investment cost for all
the measures implemented to date totals over $100 million.
O Some of the P2 measures already being implemented include:
Woodyard (Chip Handling)
chip area fencing
modify chip unloading
Pulping and Chemical Recovery
reuse condensate on washers
black liquor spill recovery
No.4 brownstock washer
upgrade recausticizing area
non-condensible gas system expansion
expansion of mill capacity with addition of recycle fiber
Bleaching
new bleach plant
chlorine dioxide plant chiller
hydrogen peroxide extraction
Pulp Dryers and Paper Machines
partial steam condensate recovery
reuse No. 14 paper machine white water at pulp mill
replace wet strength resin containing formaldehyde
General Mill Operations
No.7 power boiler
stormwater collection
replacement of PCB-containing transformers
asbestos abatement program
bulk chemical purchases to reduce drum management
eliminated use of chlorinated solvents
minimization of miscellaneous hazardous wastes
improved water conservation and reuse
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O Most of the major expenditures were for process or utility system upgrades that
provide significant P2 benefits as well as product quality and resource
utilization benefits. For example:
Installation of the No.4 brownstock washer and associated screening and
deknotting systems and the new bleach plant resulted in substantial
reduction in bleach plant chemical consumption and the amounts of
chlorinated compounds generated, while yielding bleached pulp of higher
quality suitable for a wider range of markets than would otherwise have
been possible.
Installation of the No.7 power boiler resulted in significant atmospheric
emission reductions and improved resource utilization through enhanced
combustion efficiency.
O The generation of chloroform at Simpson Tacoma has been significantly
reduced with the operation of the new bleach plant and elimination of the use of
sodium hypochlorite as a bleaching agent. The results demonstrate that
formation of chloroform can nearly be eliminated if elemental chlorine is
replaced with chlorine dioxide for pulp bleaching in the first bleaching stage.
Current operating practice at Simpson Tacoma is to operate at an average 85%
chlorine dioxide substitution rate for most grades and at 100% substitution for
selected products. Simpson Tacoma's P2 effort has reduced dioxin to non-
detect levels and AOX and chloroform by 80% and 90% respectively.
O In many cases, Simpson Tacoma has also realized cost savings from the P2
efforts. For example:
Water consumption savings of 2.9 mgd from reuse of evaporator
condensates result in an annual savings of about $300,000. The
investment cost for that measure was only $100,000.
O Simpson Tacoma's P2 accomplishments to date reflect what can be achieved at
basic industries involved in processing large amounts of materials. Major P2
benefits will accrue as production processes and utility operations are changed.
O Besides the several P2 measures already so successfully implemented,
Simpson Tacoma will be implementing additional measures over the coming
years. It is clear that Simpson Tacoma's P2 efforts will continue to be an
ongoing program.
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O Simpson Tacoma's P2 implementation plan (see 19. Pacific Northwest
Demonstration Project: Simpson Tacoma P2 Plan below), containing a
commitment to make both near-term and long-term process modifications, will be
used by Simpson Tacoma and the Washington State Department of Ecology
as a partial fulfillment of the State's requirement for a pollution prevention
plan under the State's hazardous waste law. U.S. EPA will use the plan as an
example of a successful P2 plan for the pulp and paper industry.
O This Pacific Northwest Demonstration Project also developed a model P2
plan for pulp and paper mills, for use at other mills. (See 20. Pacific Northwest
Demonstration Project: Model P2 Plan (Pulp and Paper MilH below.)
O This model P2 plan has proved useful throughout the Pacific Northwest, not only
to pulp and paper mills but also to permit writers.
O The P2 ideas and options in the model P2 plan have also been useful to
enforcement personnel in enforcement settlements.
O The Pacific Northwest Demonstration Project also produced an extensive,
annotated bibliography on pollution prevention for the kraft pulp and paper
industry. (See 21. Pacific Northwest Demonstration Project: Bibliography
below.)
As a result of this IPS Pacific Northwest Demonstration Project, Simpson Tacoma
received very favorable local and national recognition. This recognition resulted in
benefits not originally expected by the company:
First, the company gained a fresh perspective on U.S. EPA and now sees the agency
as more than just a regulator. Simpson Tacoma now has increased confidence in
dealing with the agency on technical or process related issues. Simpson Tacoma also
believes that its experience through the IPS demonstration project has shown to other
companies as well that EPA will work with companies in a cooperative manner.
Second, the recognition has brought other state and federal voluntary programs to
Simpson Tacoma that have maintained the momentum of the original IPS effort.
Subsequent to the IP3 demonstration at Simpson Tacoma and the company's
implementation of the project's P2 recommendations, a State of Washington project on
measuring pollution prevention has been conducted at the facility. In addition, Simpson
Tacoma submitted an application to U.S. EPA's Environmental Leadership Program
and was one of only 10 private companies selected nationwide! In light of the IP3's
objective to spread the P2 ethic, it is perhaps not without significance that, under the
Environmental Leadership Program, one of Simpson Tacoma's projects will be to
conduct a supplier mentoring program whereby Simpson Tacoma will now work to help
enhance the environmental performance of its suppliers.
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19. Pacific Northwest Demonstration Project; Simpson Tacoma P2 Plan
(Pollution Prevention Opportunity Assessment and Implementation Plan (EPA 910/9-92-027))
This is a P2 opportunity assessment and implementation plan for the Simpson Tacoma Kraft
Company pulp and paper mill in Tacoma, Washington. It was done by the IP3 in cooperation
with Simpson Tacoma and the Washington State Department of Ecology. It describes the mill
and its operations, the P2 opportunity assessment and its results, an evaluation of the P2 options,
and the recommended P2 implementation plan.
Value
Industry and government regulators can learn about P2 possibilities for a kraft pulp and
paper mill, as well as how to conduct a P2 opportunity assessment and develop a P2
implementation plan.
Major Findings and Conclusions
O The assessment identified and evaluated nearly fifty feasible P2 alternatives,
which are listed in Tables 4 and 5 of the document. The tables include a
description, estimated pollution reduction benefits, approximate cost, and
suggested priority of each of the P2 alternatives. Cost estimates for each
alternative range from several thousand dollars to several million dollars.
O The recommended P2 implementation plan included 17 near-term and 9
long-term P2 suggestions.
Near-term P2 recommendations (for implementation within 1 to 5 years):
(an asterisk (*) denotes the highest priority recommendations)
fugitive dust control related to chip piles *
stormwater control related to chip piles
indirect heat exchangers on batch digesters *
utilization of boiler ashes and slaker grits *
exhaust smelt tank vents to No.7 power boiler
expansion of non-condensible gas system *
black liquor spill prevention and recovery *
improved water conservation and reuse for the paper machines and pulp
dryers *
improved steam condensate recovery for the paper machines and pulp
dryers
ammonia discharge control
save-alls on pulp dryers
replacement of PCB-containing transformers *
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asbestos removal *
increased bulk purchases to eliminate drums *
minimization of miscellaneous hazardous wastes *
improved steam condensate recovery throughout mill
improved water conservation/reuse throughout mill *
Long-term P2 recommendations (for implementation within 5 to 10 years):
expand mill capacity with addition of secondary fiber
replace existing batch digester kraft capacity with addition of secondary
fiber
replace No.2 and No.3 brownstock washers
upgrade or replace No.3 recovery boiler
install new MCC (modified continuous cooking) digester for bleached
stock
expand bleach plant capacity with oxygen delignification
operate bleach plant at sustained 100% chlorine dioxide substitution
install chip thickness screens
steam strip foul condensates or incineration in power boiler.
O The P2 implementation plan also points out and discusses the importance of
and how to establish:
management commitment to P2
having a corporate framework for P2 (e.g., a P2 Committee)
incorporation of P2 within the company's planning processes (capital
appropriation and budgeting) as well as operating plans
an environmental auditing program
a tracking system for P2 successes
P2 awareness among company employees.
O Appendices to the document include:
an outline for environmental and pollution prevention planning for a
company
an extensive glossary of pulp and paper industry terms and abbreviations
a short technical description of the Simpson Tacoma mill's chlorine
dioxide substitution results.
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20. Pacific Northwest Demonstration Project: Model P2 Plan (Pulp and Paper Mill)
( Model Pollution Prevention Plan for the Kraft Segment of the Pulp and Paper Industry
(EPA 910/9-92-030) )
This is a model P2 plan for the kraft segment of the pulp and paper industry. It was developed
after the thorough P2 assessment and P2 implementation plan were done for the Simpson
Tacoma Kraft Company. Its purpose is to provide a model P2 implementation plan that can be
used for other kraft pulp and paper mills.
Value
Industry and government regulators can use this model P2 plan to establish P2 at kraft
mills throughout the Pacific Northwest and elsewhere.
Major Findings and Conclusions
O The model P2 plan contains P2 options in each of the following process areas:
woodyard operations
pulping and chemical recovery
pulp bleaching
pulp drying and papermaking
wastewater treatment
O For each P2 option, there are a description of the P2 measure, its cost, its
applicability, its benefits, and references for additional information about it.
O This model P2 plan has proved useful throughout the Pacific Northwest, not only
to pulp and paper mills but also to permit writers.
O The P2 ideas and options in the model P2 plan have also been useful to
enforcement personnel in enforcement settlements.
O This model P2 plan also presents an organizational and management
framework for establishing a P2 program at a mill, describing the importance
of:
management commitment
the establishment of a P2 team
- tracking the performance of P2 measures after implementation.
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21. Pacific Northwest Demonstration Project: Bibliography
f Pollution Prevention for the Kraft Pulp and Paper Industry: Bibliography (EPA 910/9-92-031))
This is an annotated bibliography of publications related to pollution prevention in the kraft
segment of the pulp and paper industry.
Value
Industry (and any other interested parties) is provided with a handy and extensive
reference guide to information about pollution prevention in the pulp and paper industry.
Major Findings and Conclusions
The bibliography references much information about P2 for the pulp and paper industry.
The document is organized by process area as follows:
Chip Preparation
Chemical Pulping
Pulp Washing
Bleaching
Chemical Recovery
Recausticizing
Power Generation
Wastewater Treatment
Papermaking
General Plant
The document contains 269 citations. Each citation contains: title, author,
reference, and a brief synopsis.
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22. Consumer Education Handbook ,
(Influencing Consumer Choice and Assessing the Effectiveness of Risk Communication )
This handbook provides analysis and recommendations on how and when to communicate with
the public to influence consumer choices. The underlying concept is that influencing consumer
choices (i.e., market demand) away from products that are a significant cause of pollution either
in their manufacture or in their disposal can be a very effective way to influence industry to adopt
pollution prevention.
It may not now be the role of U.S. EPA to influence consumers. But that could change. This
handbook was developed by the IP3 with the conviction that, if EPA ever does assume a
consumer education role, it is vitally important that EPA do it cautiously and be able to do it
without making mistakes. The very thorough and thoughtful analyses behind this handbook lay
that sure foundation.
Value
U.S. EPA and other environmental agencies and interest groups can learn how and when
to communicate with the public, so that it is done prudently and effectively.
Major Findings and Conclusions
Based on extensive background research and literature review, as well as the development
and testing of consumer behavior models, the handbook presents the following three
major results:
O There is an integrated framework available for examining the relationships
between consumer choices, product risks, and risk communication.
The project developed a detailed framework for evaluating the potential impact of
consumer-targeted communication suitable for use in the context of EPA
environmental policy. The method is based on a general model of consumer
choice that has been validated in applications to a diverse range of consumer
products and services.
O There is a tool for evaluating candidate products as potential subjects of a
consumer education program.
The project developed a "Product Screener." The Product Screener is to be used
to evaluate the likely success of a consumer-targeted communication campaign
for a specific product (or product category) and its associated environmental risk.
The role of the Product Screener is to reject poor candidates. (The handbook
illustrates the application of the Product Screener to three very different consumer
products: lawn pesticides, dry cleaning, and paint strippers.)
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O There is a seven-step process for prudently developing a consumer-targeted
communication strategy.
The handbook describes, and illustrates by example, the various steps to direct the
detailed design, testing, revision, and execution of a communication campaign for
the targeted product area.
The handbook is filled with detailed analyses, information, examples, and
worksheets to aid and guide the user.
23. IP3 Focus Group Recommendations: P2 Information Sharing
The 23-member IP3 Focus Group (comprised of representatives from industry, labor,
environmental groups, academia, and all levels of government (federal, state, and local))
provided recommendations on the best ways to disseminate P2 information.
Value
Anyone interested in disseminating P2 information can learn what the stakeholders
themselves recommend.
Major Findings and Conclusions
To disseminate P2 information most effectively, the IP3 Focus Group recommended
doing so through:
O training of permit writers
O meetings with targeted audiences (not just sending them material)
O standardized dissemination systems (rather than informal ad hoc ones)
O university-based assistance programs
O non-regulatory agency assistance programs
O trade associations and other professional associations
O professional environmental auditing organizations
O the television medium
O the video cassette medium
O business publications (e.g., Business Week)
O state industry councils
O Chambers of Commerce
Whatever method is used, unless the audience is known to be technically oriented, be sure
to translate the P2 information into "management's language."
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Questions about the IPS or requests for any of the IPS documents can be addressed to:
Jim Lund
Director, IPS
U.S. EPA
401M Street, S.W.
Washington, DC 20460
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